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DRAFT — pending legal review. Not a final legal document. Placeholders in brackets are unresolved.
ProClimber Simulator
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Privacy Policy

Draft version 0.1 · last edited 2026-07-12

1. Who we are

ProClimber Simulator is developed and operated by [ENTITY NAME] ("we", "us"), based in Latvia. [Registered address and, once assigned, EU representative / DPO contact - pending legal review]. For any privacy question, reach us at hello@proclimber.quest.

2. What we collect

  • Device and guest identifiers. A random device ID lets a guest profile keep its progress on that device. No account creation is required to play.
  • Google account data (optional). If you choose to link a Google account, we receive your Google account identifier and the email/display name Google shares, so progress can sync across your devices.
  • Age-gate answer. Your age, asked once, used to derive an age bracket (adult / minor) and, for players under 13, to refuse account creation. We store the resulting bracket and a derived birth year, not your exact date of birth.
  • Gameplay and progression data. Career state, sends, gear, wallet balance, and similar data needed to run the Game.
  • Purchases. Once the store opens: which items or currency packs were bought and when. Card and payment details are handled entirely by the platform or payment processor you buy through; we never see or store full payment card numbers.
  • Support and feedback submissions. Anything you send us voluntarily (bug reports, replays attached to a report, contact emails).
  • Basic technical data. App version, viewport size, controller-connected state, and similar diagnostic fields attached to crash/error reports.

We do not knowingly collect more than the above, and we do not buy data about you from third parties.

3. Why we process it

To provide the Game and your account (contract necessity); to keep the shared world, economy, and competitions fair and secure (legitimate interest); to comply with age-verification and consumer-protection law (legal obligation); and, where you opt in, to sync progress via Google sign-in or to send you release updates you requested (consent, revocable at any time).

4. Children's privacy

The Game is not directed at children under 13, and the age gate refuses account creation below that age (COPPA, US). For players aged 13-17 in the EU/EEA, we rely on the age-bracket flag to apply reduced purchase limits and to keep chat off by default, consistent with GDPR Article 8 guidance on information-society services offered to minors. If we learn that we collected data from a child under 13 in violation of this policy, we will delete it.

5. Who we share it with

  • Google, only if you choose to link a Google account (Google Sign-In).
  • Our infrastructure providers that host the game server and database, acting under our instructions as processors.
  • Payment platforms (once the store opens), to process purchases and validate receipts.
  • Legal or safety disclosures, where required by law or to investigate abuse, fraud, or a Terms of Service violation.

We do not sell personal data.

6. Data retention

Gameplay and account data is kept for as long as your account is active, plus a limited backup retention window (nightly backups are rotated on a 30-day cycle). You can request deletion at any time (§7); some records (e.g. purchase records) may be retained longer where required by tax or consumer law.

7. Your rights (GDPR and equivalent laws)

Depending on where you live, you may have the right to: access the data we hold about you; correct inaccurate data; request erasure; restrict or object to processing; receive a portable copy of your data; and withdraw consent at any time without affecting processing done before withdrawal. You can also lodge a complaint with your local data protection authority. To exercise any of these, contact hello@proclimber.quest.

8. Security

We apply reasonable technical and organizational measures (encrypted transport, access controls, secrets kept outside application code) to protect your data. No system is perfectly secure; we will notify affected players and authorities as required by law if a breach occurs.

9. International transfers

[Hosting region and transfer safeguards - pending legal review; infrastructure is currently EU-hosted].

10. Cookies and local storage

The Game itself uses browser local storage, not tracking cookies, to remember your device ID, settings, and age-gate answer on your device. The marketing site (this page) does not set advertising or analytics cookies.

11. Changes to this policy

We may update this policy as the Game and its systems (store, competitions, UGC) develop. Material changes will be flagged in-game before they take effect.

12. Contact

hello@proclimber.quest

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